The intent of the depreciation recapture rules is to reclassify gains which are due to the deduction of depreciation (an ordinary expense deduction) as ordinary income, rather than either capital gain or Section 1231 gain.

Section 1245 recaptures all gain which is due to the depreciation deduction as ordinary income.  For there to be either a capital gain or a Section 1231 gain on a Section 1245 asset, the asset must be sold for more than its original cost.  That is, only the true appreciation in the price of a Section 1245 gain is accorded capital gain or Section 1231 gain status.

Section 1250 recaptures excess depreciation as ordinary income.  Excess depreciation is defined as the actual depreciation deducted less the allowable straight-line depreciation.  Therefore, straight-line depreciation on Section 1250 assets can create capital gain or Section 1231 gain.  As long as a straight-line depreciation is taken on a Section 1250 asset, no recapture occurs.